CMS Updates Functional Limitation Reporting Requirements

The Centers for Medicare and Medicaid Services (CMS) has
further clarified the regulations on the new functional limitation reporting
requirements that were included in transmittal R2622CP and a new Medicare Learning Network resource. CMS was mandated to collect information on claim
forms regarding beneficiaries' function and condition, therapy services furnished,
and outcomes achieved on patient function by the Middle Class Tax Relief Act of
2012. All practice settings that provide outpatient therapy services must
include this information on the claim form. These new functional limitation
reporting requirements were implemented on January 1. To ensure a smooth
transition, CMS sets forth a testing period January 1-July 1. After July 1,
claims submitted without the appropriate G-codes and modifiers will be returned
unpaid.

The major points of clarification include:

Guidance
on using the “Other PT/OT” functional limitation category

Submission
of functional limitation data for more than 1 therapy plan of care

APTA has posted links to these documents on its functional limitation reporting webpage. The association also has updated the FAQ
posted on the webpage, which provides resources to help members meet this new
reporting requirement.